comparative analysis on the role of financial fines in enforcement of competition rules

financial fines are regarded as a powerful implement in the hand of competition authorities which apply in the way of ceasing anticompetitive practices and hindering undertakings from entering into monopolization activities.  having regarded the nature and main function of this sanction, this paper in comparative study is going to clarify executive domain and primary stages of fine determining and also the fundamental factors which should be accounted in such process. results derived from comparative study manifest that iranian competition law's approaches as to pecuniary fine suffer from serious deficiencies and its general, ambiguous and unusual regulations need fundamental review and attending to notions and measures which may be unrecognized or ignored in our law framework. this situation indicates the increasing importance of pursuing the most efficient solutions of other legal systems.